pre-change loss
Defined in 1 place of the United States Code.
The term “pre-change loss” means—
(A) any net operating loss carryforward of the old loss corporation to the taxable year ending with the ownership change or in which the change date occurs, and
(B) the net operating loss of the old loss corporation for the taxable year in which the ownership change occurs to the extent such loss is allocable to the period in such year on or before the change date.
Source
- 2013–present26 U.S.C. § 382Internal Revenue Code · Limitation on net operating loss carryforwards and certain built-in losses following ownership change · for purposes of this section
The term "pre-change loss" means—
(A) any net operating loss carryforward of the old loss corporation to the taxable year ending with the ownership change or in which the change date occurs, and
(B) the net operating loss of the old loss corporation for the taxable year in which the ownership change occurs to the extent such loss is allocable to the period in such year on or before the change date.
Except as provided in subsection (h)(5) and in regulations, the net operating loss shall, for purposes of subparagraph (B), be allocated ratably to each day in the year.
Source
- 1994–201926 U.S.C. § 382Internal Revenue Code · Limitation on net operating loss carryforwards and certain built-in losses following ownership change · for purposes of this section
The term "pre-change loss" shall include any carryover of disallowed interest described in section 163(j)(2) under rules similar to the rules of paragraph (1).
Source
- 2017–present26 U.S.C. § 382Internal Revenue Code · Limitation on net operating loss carryforwards and certain built-in losses following ownership change · for purposes of this section